The Historic Tax Credit: A Practitioner's Guide to the Technical Tax Issues, 2nd Edition

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William Fletcher Machen

The Historic Tax Credit

A Practitioner's Guide to the Technical Tax Issues, 2nd Edition

William Fletcher Machen

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English

American Bar Association
18 June 2024

Offences against the government; Taxation & duties law

"Section 47 of the Internal Revenue Code of 1986, as amended (the ""Code""), allows taxpayers to claim a credit (the ""Rehabilitation Tax Credit"") for certain expenses incurred in connection with the rehabilitation of older or historic buildings. The amount of the credit is 20 percent of the ""qualified rehabilitation expenditures"" incurred in connection with a ""certified rehabilitation"" of a ""certified historic structure"" or 10 percent of the qualified rehabilitation expenditures incurred with respect to a nonresidential building placed in service before 1936.

A certified historic structure is a building that either is listed as such in the National Register of Historic Places (the ""National Register"") or is located in a ""registered historic district"" and is certified by the Secretary of the Interior (the ""Secretary""), acting through the National Park Service (the ""NPS""), as being of historic significance to the district.

A registered historic district includes any district listed in the National Register, as well as a district statutorily designated by a state or local government, provided that the relevant statute has been certified by the Secretary as incorporating proper criteria for substantially achieving the purpose of preserving and rehabilitating historically significant buildings, and the district is certified by the Secretary as satisfying substantially all of the requirements for the listing of districts in the National Register."

By: William Fletcher Machen
Imprint: American Bar Association
Country of Publication: United States
Dimensions: Height: 152mm, Width: 228mm,
ISBN: 9781639053926
ISBN 10: 1639053921
Pages: 142
Publication Date: 18 June 2024
Audience: General/trade , ELT Advanced
Format: Paperback
Publisher's Status: Forthcoming

Mr. Machen is a tax lawyer specializing in real estate syndication and partnership matters. He has represented syndicators, investors, and developers for almost 50 years in numerous transactions involving the construction and/or rehabilitation of subsidized and conventionally financed multifamily residential projects, office buildings, shopping centers, and sport stadiums, as well as energy facilities. In addition to this book, he is the co-author of the BNA/Bloomberg Tax Management Portfolio on the Low-Income Housing Tax Credit and has been a frequent speaker over the years at industry seminars. He is a former director of the National Housing and Rehabilitation Association and received that organization's 2015 Vision Award for his contributions to affordable housing and community development. He also served as a director and committee chairman of the Historic Tax Credit Coalition and, together with other members of that organization, was actively involved in the negotiation of the IRS historic tax credit safe harbor in Revenue Procedure 2014-12. Mr. Machen currently is of counsel to the law firm of Holland & Knight, LLP where he was a partner for many years.